1. The Trustees of the Morrison 2002 Maintenance Trust, 2. The Trustees of Sir Fraser Morrison's 1989 Trust, 3. The Trustees of Sir Fraser Morrison's 1995 Trust, 4. Sir Fraser Morrison v The Commissioners for HM Revenue and Customs: [2017] UKUT 0300 (TCC)

Upper Tribunal Tax and Chancery decision of Mr Justice Arnold and Judge Berner on 3 August 2017.

• From: HM Courts & Tribunals Service and Upper Tribunal (Tax and Chancery Chamber)
• Published: 4 August 2017

• Category: Tax
• Release date: 3 August 2017

Read the full decision in 1. The Trustees of the Morrison 2002 Maintenance Trust, 2. The Trustees of Sir Fraser Morrison’s 1989 Trust, 3. The Trustees of Sir Fraser Morrison’s 1995 Trust, 4. Sir Fraser Morrison v The Commissioners for HM Revenue and Customs: [2017] UKUT 0300 (TCC).

Capital Gains Tax – tax avoidance scheme taking advantage of section 144ZA Taxation of Chargeable Gains Act 1992 – sale of shares by Scottish Trustees to Irish Trustees pursuant to exercise of put option followed by sale by Irish Trustees – whether single composite transaction

Published 4 August 2017